Export Control Concerns: Travel & Shipping

Travel

Travel to most countries does not usually constitute an export control problem. In most cases, items such as a personal laptop computer and other “tools of the trade” do not require a license. A license would be required if you are taking an item found on the Department of State’s U.S. Munitions List (USML). Travel to certain embargoed or sanctioned terrorist countries would require a license from the Office of Foreign Asset Controls (OFAC), or could, in fact, be denied. In addition to OFAC’s license requirements, the Bureau of Industry and Security (BIS) would require a license to take any items found on the BIS Commerce Control List (CCL). For example, a license would be required to take any laptop computer if you were traveling to a sanctioned or embargoed country. There are also regulations about securing licensed items and returning them to the U.S.

The Department of State, OFAC, and BIS also have various lists of persons and entities that you are prohibited from doing business with; in other words, we should not be providing them with a defense service (includes training), giving money to these people or organizations, or providing them with controlled (on the CCL) proprietary technology. We can be fined by the government agencies if we do business with any person or entity found on these lists. Links to the Department of State, BIS, OFAC, denied entities/persons lists, and the “Countries of Concern” can be found at Visual Compliance.

Shipping

Shipping items outside the U.S. could require a license from OFAC, the Department of State, or the BIS. Check with Valerie Howard, Director of Sponsored Programs to determine if a license is needed. An OFAC license takes six months to receive, a license from the Department of State takes two months, and a license from the BIS takes approximately two weeks, so allow plenty of time before you need to ship. Do not ship an item without going through Mailing Services because if customs audits your shipment, and a license was required and not in place, you and WSSU would be fined.